Schulman v. Commissioner
United States Tax Court
P, under his employment contract as administrator of hospital H, was provided an option to purchase partnership units at a fixed price over a 4-year period. The options were not traded on an established market and were subject to restrictions which applied if P's employment was terminated or he wished to sell the options or interest.
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P, under his employment contract as administrator of hospital H, was provided an option to purchase partnership units at a fixed price over a 4-year period. The options were not traded on an established market and were subject to restrictions which applied if P's employment was terminated or he wished to sell the options or interest. After P advised of his intent to exercise the option, H, unbeknownst to P, entered into negotiations to sell its business to U. On or about Mar. 31, 1979, P pledged his option-acquired partnership units to collateralize a loan to purchase the units. P became…
1Opinion of the Court
GERBER, Judge:
Respondent determined deficiencies in petitioner’s 1979 and 1980 income taxes of $9,568 and $260,745, and additions to tax under section 6653(a)1 of $478.40 and $13,038, respectively. By amendment to his answer, respondent alternatively asserted deficiencies of $344,911 and $16,571, and section 6653(a) additions to tax of $17,245 and $829 for 1979 and 1980, respectively. After concessions or agreements by the parties, the issues remaining for our consideration involve the tax consequences, if any, upon petitioner’s exercise of an option to purchase partnership units in Valley…
2Cases cited23 opinions
- Neely v. CommissionerUnited States Tax Court · 1985
- Carlos and Jacqueline Marcello v. Commissioner of Internal Revenue, Joseph, Jr. And Anastasia Marcello v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1967
- Stange v. United StatesSupreme Court of the United States · 1931
- Estate of Andrews v. CommissionerUnited States Tax Court · 1982
- Adler v. CommissionerUnited States Tax Court · 1985
18 more not listed; retrieve them via the Exa API.
3Cited by30 opinions
- Amesbury Apartments, Ltd. v. CommissionerUnited States Tax Court · 1990
- Mecom v. CommissionerUnited States Tax Court · 1993
- KORFF v. COMMISSIONERUnited States Tax Court · 1993
- Kimberlin v. Comm'rUnited States Tax Court · 2007
- Metals Refining, Ltd. v. CommissionerUnited States Tax Court · 1993
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